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May012017

Industrial Hazardous Material Decontamination

Industrial Haz Mat Decontamination

          There are many points to consider when coordinating a Hazardous Materials Response “Team” for your facility. A large consideration is the module of  “Decontamination.” What kind of equipment shall you use? Who will be the responders? How can you design this operation for “return-to-normal” for business operations in the shortest time period? How will you store the resulting waste short-term? How do I motivate hazardous material workers in this field? What template should be used to align your “system” as to how it operates? What safety considerations need to be accounted for?

For Industrial facility hazardous material workers, when considering decontamination the process must be simple and thorough. How the worker responds is of grave consideration when designing an optimum system for facility functions. If your workers are not designated and specifically employed for “Hazardous Waste Operations” this influences many operational procedures you may want to use. Like any other profession, the more frequent an employee performs the task, the better he will become. If performance is seldom, grave problems can arise. Hence the need to keep procedures safe and simplistic. Decontamination systems that require less training while fully decontaminating the personnel and “affected” areas/equipment, will serve infrequent responders best.  

The bench marks for most hazardous spill decontamination systems are the universal solvents of soap and water. This of course rules out any water reactive substances that you may use in industrial applications. For these, a more considered and diverse solvent “system” must be designed by the management leadership. One common “system” outside hazardous materials responders like to use on industrial sites is the facilities decontamination “safety showers.” These are commonly placed by industry throughout the plant at locations where workers who become accidentally “contaminated” by spills or processes can quickly use them to wash off toxic contamination. Most, (but all should be by law) are drained into plant chemical holding tanks for later removal by a hazardous waste vendor of the facility choice. Note, that it is illegal to drain diluted hazardous materials into storm or combination municipal waste systems. This is a clear violation of environmental laws. If your plants’ system does NOT drain into a proper chemical storage tank separated from non-hazardous waste streams, this must be corrected before using your safety showers for hazardous material decontamination.

The limitation of use for safety showers is usually location. Sometimes the distance between spill sites and decontamination/safety showers is too great of a distance for the response Team. The solution equipment wise is to adapt one of these safety showers to mobile use. One we used at an industrial site was very well set-up in a properly planned manner. A metal “HAWS” safety shower was mounted to a pallet sized spill containment skid which allowed for transportation throughout the facility by company high-low operators. It was mounted with back-flow drains for use outside the plant structure in inclement weather. All that was required is heated water. The entire system required the unit, water intake line, and “if” a prolonged incident, a discharge line to empty the containment pallet when full. Ours’ had a portable pump to transfer the contents into drums when it became full, very slick. Training for set-up by plant personnel was straightforward and minimal, use of a shower is universal and equipment costs are minimal providing a versatile and capable decontamination system. Additionally, untrained new employees, or plant guests are still able to use this system “shower” in the advent of an emergency. Whatever system you design should be as simplistic as this one for positive decontamination techniques and ease of use. These types of solutions demonstrate strong leadership within and by the Team Leader.

What employees are to be designated for this work? If you use out-side contractors your planning is minimal. Their organization is responsible and capable for all elements of an operation. Your only concern is giving them access and response time. Response times can vary depending on location and this may not fit well into your “return-to-business” operational time periods. This is the primary reason for on-site facility responders. If your employees are regular site workers with daily tasks to complete, removal of them to answer a response call may cause production problems. Many facilities hesitate to send these employees off-site for needed classes and on-going training due to the issues associated with temporarily replacing them. Over-time, schedule re-configurations, and other needs regarding these employees are often taken too high in consideration vs. the information and needed training they will receive from up-dated training or re-fresher courses . If your employees specifically exist to handle plant emergencies, the issue may be which one of your facilities are they currently located at? Is there a response time issue in arriving at your site location? All of these items need to be evaluated BEFORE you designate who will respond from your facility. By narrowing down he needed operational priorities, you will be able to determine which choice of workers will best suit your company’s needs.

“Returning-to-Business” needs are understandably one of the most primary concerns for business management and sometimes Team Leaders.  For a truly sustainable result at any spill or incident, the primary focus MUST be safe operations that solve ALL issues resulting from the incident. Once your Team has successfully mitigated the incident, check all involved and ancillary equipment connected to or nearby the incident site. This provides needed maintenance and often eliminates future production shut-downs due to a smaller issue that could have also been corrected at the time of the spill. Once you are down, USE that time to correct ALL issues is much more cost efficient than having to shut-down “again” for another small maintenance task. Many managers do not appreciate this concept, so it will have to be sold on its true merits of making the overall business operation more profitable in the long run. Once these needs have been met, you will find fewer shut-downs over the years and greater production benefits for your business. These profit increases need to be recognized that they exist because of your emergency response Team. So the sustainability of your corporate Team actually increases your bottom line, good to remember and appreciate when response Team needs are required.

Waste storage from a hazardous materials incident is important to pre-plan. If your facility does not have an “EPA 90 day short term storage license” you have 96hrs from the onset of the initial incident to have all spill waste properly packaged and off your site through the use of a properly licensed EPA hazardous waste transported. This is often the case, as these licenses frequently cause local site ordinance issues with the surrounding neighborhood. So, refreshing your contacts with your local hazardous waste transportation contractor is always a good idea. From experience it is always nice to see a friendly face at 0300hrs, than an adversary during a hazardous materials incident.

The motivation of your response Team working culture is critical to Team success.  If workers are volunteering to perform these tasks (as most are) an appropriate incentive must materialize for them to remain interested in the corporate Team. Often this is NOT additional monies but something else. The Team Leader which is often from a management position must figure out “what-the-team-wants”. It may range from shift preference all the way to better recognition, but whatever it “IS”, for your group, by delivering it or moving forward in that overall direction will strengthen the Team interest and solidify success. The best way to research and strengthen this bond/goal is to host frequent Team Meetings where important worker issues can be remedied. This effort demonstrates corporate interest in the “Team” as opposed to just “getting-what-they-want”. Team “leadership” is a mutual forward progression for improvement, whereas management equates to local control. Contemplation of these concepts is essential for a positive Team/corporate relationship to flourish.

If you are searching for the correct ‘Template” for overall Decontamination organization an excellent source lays in 29 CFR 1910.1200(q) (2) (vii).

   “Decontamination means the removal of hazardous substances from employees and their equipment to the extent necessary to preclude the occurrence of foreseeable adverse health affects.”

This is the Gold standard and should serve as the master template at all facilities in all countries throughout the globe. This standard affords the safest concept and yet affords the greatest leniency or adaptation to its guidelines. All USA response teams follow this ruling just for this reason.  This standard was written for consolidation of response practices. By doing this, any Team following these guidelines is capable of functioning with any mutual aid organization for mass disaster incidents. When considering the current political/terrorist climate, it is comforting to know that all responders to your facility shall cooperatively blend, when working on large problems.

At a minimum, whichever decontamination format you and your team decide on, the minimum safety considerations should be implemented.

1] Respiratory Protection

2] CPC (Chemical Protective Clothing) Ensemble’  

3] Proper Equipment (Decontamination System)

For whichever task your Team is slated to perform, they MUST have the proper equipment. This does not mean every piece of equipment in the cadre’, but does mean the equipment necessary to accomplish the task safely. In other words, equipment must enable the worker to safely carry out his/her duties. If you are going to move 500 gallon totes on-site, you have to have a high-low. Physical labor must be provided with mechanical equipment to render safe operations for assigned tasks at hand. When these concepts focused on, corporate Hazardous Material Response Team success greatly increases.

                Haz Mat Mike

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